January 25, 2016

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

RE: Exemption Request Pursuant to Section 333 of the FAA Modern ization and Reform Act of 2012, 49 U.S.C. § 44701(f), and Part 11 of the Fe deral Aviation Regulations

Dear Sir or Madam:

We represent Jorge Delgado and are submitting this Petition for Section 333 Exemption on his behalf under Section 333 of the F AA Modernization and Reform Ac t of 2012 (“FMRA”).

Applicant Information:

The name of the applicant: Jorge Delgado

The primary contact for this application, with a copy to me at the address above, is:

Jorge Delgado 16840 SW 278 th Street Homestead, FL 33031

Jorge Delgado is a United States citizen residing in the State of Florida. Pursuant to Section 333 of the FMRA, Jorge Delgado hereby requests a determination by t he Secretary of Transportation authorizing commercial operations of UAS for the purposes of ae rial photography, aerial videography, data collection and other work related to aerial p hotography in the NAS. Jorge Delgado does not intend to use for closed set filming . Conduct of UA operations will be with respect to FMRA Section 333(c) and the UAS “Blanket COA”. Pet itioner is seeking an exemption to commercially operate sUAVs makes and models, as fo llows:

1. 3D Robotics Aero – M 101. HexaCrafter HQ-850 2. 3D Robotics Fixed Wing 102. HexaCrafter HQ-1150 3. 3D Robotics Iris 103. HobbyKing Bixler 2 4. 3D Robotics Solo 104. Hoverfly – Livesky 5. 3D Robotics X8 105. HSE UAV – DRASS Q1000
6. 3D Robotics X8+ 106. Hubsan – X4 Microdrone
7. 3D Robotics X8-M 107. Inova Drone – Inova OneJanuary 25, 2016 Page 2 of 13

8. 3D Robotics Y6 108. Intuitive Aerial – Aerigon IAH 3 9. AeroCamera - SR 15 109. Kespry Drone Systems
10. Aerial Pixels - Fx8Pro E lite 110. KongCopter FQ700
11. Aerialtronics Altura Zenith 111. Latitude Arcturus Jump-15 12. AeroCine Kopterworx Hammer X12 112. Latitude Arcturus Jump- 20 13. AeroLogix – Geostar 113. Latitude HQ-20 14. Aeronavics SkyJib-8 Ti-QR 114. Latitude HQ-40 15. Aeronavics X4 Titanium 115. Latitude HQ-60 16. Aerosky – RoboSurfer 116. Latitude Sensitel Silverfox HQ 17. AeroVironment Puma 117. Leptron – Avenger 18. AeroVironment Qube 118. Loc kheed Martin – Desert Hawk III 19. AeroVironment Shrike 119. Lockheed Martin – Indago 20. Aeryon Scout 120. Mavinci – Sirius Pro 21. Aeryon Sky Ranger 121. Microdrones MD4 22. AgEagle 122. Microdrones – MD4-200 23. Agribotix Enduro Quad 123. Microdrones – MD4-1000 24. Agribotix Hornet Drone 124. Microdrones – MD4-3000 25. Aibotix X – 6 125. MikroKopter – ARF OctoXL 26. AirCover ORT-825 126. MLB- Super-Bat UAV 27. AirCover QR-425 127. Multirotor G4
28. Airfield – Extreme Surfer Power Glider 128. MultiRotor – G4 Blackbird V2 29. AirRobot AR 100-B 129. MultiRotor – G4 Skycrane
30. AirRobot AR 100-C 130. Parrot – AR Drone 2
31. AirRobot AR 180 131. ParkZone – Radian RTF 32. AirRobot AR 200 132. Parrot – Bebop 33. Airwing UAV – Talon 133. PrecisionHawk – Lancaster 34. Align M690L Multicopter 134. Precision Drone – PaceSetter
35. Altavian Nova F6500 135. Prioria – Hex
36. Altus UAS Delta X-4 136. Prioria – Hex Mini
37. Altus UAS Delta X-8 137. Prioria – Maveric UAS 38. American Drones – Eagle 550 138. ProJet – RC Drone 39. American Drones – Falcon 450 139. ProJet – RQ-11 Raven 40. American Drones – Nighthawk 550 140. Pulse Aerospace – Scou t B1-100 41. American Drones – Phoenix 650 141. Pulse Aerospace – Vapor 42. Arch Aerial – Atlas-1 142. RangeVideo – Jet
43. Arch Aerial – OCTO 143. RF70 Aircraft 44. ARRIS – M680 Hexa 144. RIEGL RiCopter 45. Ascending Technologies – AscTec Falcon 8 145. Ritewing - Dr ak 46. Birdseyeview – FireFly 6 146. Ritewing - Spade 70" 47. Blade 350 QX3 147. Ritewing - Zephyr 3 Spade 48. Blade Chroma 148. SenseFly eBee 49. Bormatec – Maja UAV 149. SenseFly – eXomJanuary 25, 2016 Page 3 of 13

50. Bumblebee Carbon Fiber Quadcopter 150. Sensurion Aerospace – Magpie 51. CarbonCore – Cortex ARTF 151. Skycatch 52. CineStar – 6 MK Heavy Lift RTF 152. Skyhunter 53. Cinestar 8 Octo 153. Skywalker X-8 54. Cyber Technology – Cyber Quad 154. Splash Drone
55. Delair-Tech – DT – 18 155. SteadiDrone – Flare
56. DJI-F450 156. SteadiDrone – Mavrik
57. DJI-F550 157. SteadiDrone – Vader 58. DJI - Inspire 1 158. Swift Radioplanes – Lynx
59. DJI – Matrice 100 159. T-Rex 800E Pro 60. DJI - Phantom 2 160. Tactical Robotics – InstantEye Mk2
61. DJI - Phantom 3 161. Tarot – 450 62. DJI – Spreading Wings S800 162. Tarot – 690 63. DJI – Spreading Wings S900 163. Tarot – 960 64. DJI – Spreading Wings S1000 164. Tarot- 680 Pro 65. DJI – Spreading Wings S1000+ 165. Tarot – T18 66. DraganFlyer - Commander 166. Tarot – T810 67. DraganFlyer - Guardian 167. Tayzu Robotics – Quadra 68. DraganFlyer - X4-ES 168. Tayzu Robotics – Titan X8 69. DraganFlyer - X4-P 169. TBS Caipirinha V2 70. DraganFlyer – X6 170. Trimble UX5
71. Event 38 - E384 171. Trimble UX5-HP 72. Finwing – Penguin 1720 172. Trimble ZX5 73. FlyPro PX400 173. Turbo Ace – Cinewing 6
74. FoxTech FPV – D130 X8 V2 174. Turbo Ace – Matrix G
75. FoxTech FPV – K130 V3 175. Turbo Ace – Matrix I 76. Freefly – Alta 176. Turbo Ace – Matrix E
77. GB-250z 177. Turbo Ace – Matrix S 78. GB-450z 178. Turnigy Talon Quad 79. Germap – G47-X8 179. UAV Solutions – Phoenix 30 80. Germap – G65-Y6 180. UAV Solutions – Phoenix 60 81. Germap – G180 181. UAV Solutions – Phoenix 60LE 82. Germap – G212 182. Vanguard Defense Industries ShadowHawk 83. Germap – SmartOneC 183. Viking UAS – Patriot X4 84. Gryphon Dynamics – Dodeca 184. Viking UAS – Patriot X8 85. Gryphon Dynamics – Hexa 185. Viking UAS – Ranger EX 86. Gryphon Dynamics – Octo 186. Viking UAS – VikingOne 87. Gryphon Dynamics – X8 187. Viking UAS - VK X6 Model 800 88. Gryphon Dynamics – Y6 188. Volt Aerial Robotics - Venture 89. Hawkeye 1700 189. Vulcan – Black Widow 90. Hawk UAS – Silex Systems F15 190. Vulcan – Mantis 91. Helipal - Storm Drone An tiGravity 191. Vulcan – RavenJanuary 25, 2016 Page 4 of 13

92. Helipal - Storm Drone 4 192. Walkera – QR X350PRO 93. Helipal - Storm Drone 4 Mini 193. Walkera – QR X800 94. Helipal - Storm Drone 4 N aza 194. Walkera – QR X900 95. Helipal - Storm Drone 6 Naza 195. Walkera – Scout X4 96. Helipal - Storm Drone 8 Naza V2 196. Walkera – Tali H500 97. HexaCrafter HC-650 197. Walkera – Voyager 3
98. HexaCrafter HC-800 198. Yamaha RMAX
99. HexaCrafter HC-1100 199. Yuneec - Tornado H920 100. HexaCrafter HO-1250 200. Yuneec - Typhoon Q500

Each separately weighs 55 lbs. or less, with imaging payload an d applicable equipment.

Equipment operation manuals for each sUAV are included for your reference and are considered confidential information for each respective company’s UAS and are affixed separately in these documents labeled Appendix, which has been sent to the FAA elec tronically by email. The referenced Appendixes are conf idential and proprietary and is n ot to be publicly disclosed.

Exemption is necessary to effect the determination requested pu rsuant to FMRA Section 333. The attached documentation includes detailed exemption requests that demonstrate how these exemptions are in the public interest and will maintain at leas t an equal level of safety to existing regulations. Authorizing Jorge D elgado to conduct commercial UA S operations will result in less disruptive, safer, and more cost effective solutions than manne d aviation equivalents due to the low altitude environment, given the size, speed and inherent ri sk of traditional commercial helicopter operations. These comm ercial operations often occur in the unsafe areas of the heightvelocity diagram requiring speci al precision and skill. Jorge D elgado will conduct the commercial UAS operation in a manner that will meet, and in man y cases exceed, the current level of safety of commercial he licopter operations. UA that ar e under 55 lbs., have a low noise signature, and carry no volatile fuel, will limit collateral da mage in the event of catastrophic failure. The low expense of operation compared to cost prohibit ive manned aviation alternatives allow a greater economic benefit to businesses. For these reaso ns, granting an exemption under FMRA Section 333(c) is in the public interest. UAS technology u sed for these commercial purposes benefit the public inter est in the following ways:

 Reduces the collateral damage risks to life and property associ ated with low altitude helicopter operations in undesi rable portions of the height-vel ocity envelope.

 Increased economic wellbeing to local businesses via cost reduc tions.

 Enabling aerial business solutions to be available to a larger market.January 25, 2016 Page 5 of 13



### Table of Contents

I. Exemptions Requested II. Commercial Operation/Operator III. Unmanned Aircraft System (UAS) IV. UAS Pilot-in-Command (PIC) V. Public Interest VI. Summary VII. List of Attachments

I. Exemptions Requested

Pursuant to 14 C.F.R. § 11.81(e), Jorge Delgado requests exempt ion from the following regulations:

 14 C.F.R. Part 21 Subpart H – Air worthiness Certificates

o Establishes: The procedural requirements fo r the issuance of airworthiness certificates as require d by 14 C.F.R. § 91.203(a)(1)

Given the small size of the UA a nd the safeguards that will be taken as outlined below, an exemption from Part 21 Subpart H m eets the requirements of an e quivalent level of safety under Part 11 and Section 333 of the FMRA with consideration “o f the size, weight, speed, operational capability, and proximity to airports and po pulated areas of the particular UAS.”

 14 C.F.R. § 45.23(b) – Aircraft Marki ng and Identification Requ irements

o When marks include only the Ro man capital letter "N" and the re gistration number is displayed on limited, restricted or light-sport categ ory aircraft or experimental or provisionally certificated aircraft, the operat or must also display on that aircraft near each entrance to the cabin, cockpit, or p ilot station, in letters not less than 2 inches nor more than 6 inches high, the words " limited," "restricted," "light-s port, "experimental," or "provisional," a s applicable.

Jorge Delgado will ensure complia nce with § 45.29(f) to meet th e intent of the regulation by displaying the registration num ber in the largest practicabl e lettering.

 14 C.F.R. 61.113 (a)(b) and 61.133(a)(1)(ii) and 61.101 – Recr eational, Private and Commercial Pilot Privilege and Limitations

o 14 C.F.R. § 61.113: (a) Except as provided in paragraphs (b) through (g) of this section, no person who holds a pri vate pilot certificate may ac t as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connect ion with any business or emplo yment.January 25, 2016 Page 6 of 13

o 14 C.F.R. § 61.133 : (a) Privileges – (1) General. A person who holds a commercial pilot certificate may act as pilot in command of an aircraft – (ii) For compensation or hire, provided th e person is qualified in accor dance with this part and with the applicable parts of this chapter that apply to the operation.

o 14 C.F.R. § 61.101 : (a) A person who holds a recreational pilot certificate may not act as pilot in command of an aircraft:

 For compensation or hire;

 In furtherance of a business;

UA operations will employ a PIC who holds, at a minimum, a recr eational or sport pilot certificate of any category or cla ss and a valid d river’s licen se.

 14 C.F.R. 91.7(a) – Civil Ai rcraft Airworthiness

o No person may operate a civil air craft unless it is in an airwo rthy condition.

The PIC will conduct daily pre and post flight inspections in a ccordance with manufactures maintenance manual( s) and guidance. During flight, the PIC will adhere to § 91.7(b) and abort air operations immediately upon identificat ion of an in-flight emergency or other unsafe condi tion. By complying with procedur es outlined by the manufacturer, an equivalent level of safety will be achieved.

 14 C.F.R. 91.9(b) Civil aircraft flight manual, marking, and pl acard requirements

o (b)(2) prohibits operation of U. S.-registered civil aircraft un less there is available in the aircraft a current approved Airplane or Rotorcraft Fligh t Manual, approved manual material, markings, and pl acards, or any combination the reof.

By keeping all operating documents, manuals, authorizations and exemptions in a binder co-located with the GCS, Jorge Delgado meet the intent of the r egulations and therefore achieve an equivalent level of safety.

 14 C.F.R. 91.109(a) – Flight Instruction

o No person may operate a civil airc raft (except a manned free ba lloon) that is being used for flight instruction unle ss that aircraft has fully func tioning dual controls.

The majority of sUAS by design ar e developed with single operat ional control through the use of pre-determined GPS enabled waypoints programmed befo re or during flight in addition to the use of a single hand held transmitter or contro l station controlled by the PIC. The design does not allow for dual controls during flight training and therefore the exemption is requested to trai n operators, build experience, an d maintain proficiency. An equal level of safety will be achieved by conducting all traini ng in sterile environments. Training sessions will be accomp lished separately from flights conducted for compensation or hire.January 25, 2016 Page 7 of 13

 14 C.F.R. 91.119 (c) – Minimum Safe Altitudes

o Except when necessary for takeoff or landing, no person may ope rate an aircraft below the following altitudes: (b) Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitu de of 1,000 feet above the highest obstacle with in a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet ab ove the surface, except over open water or sparsely populated areas. In those ca ses, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. (d) Helicopters, pow ered parachutes, and weight-shif t-control aircraft. If the operation is conducted without hazard to persons or propert y on the surface— (1) A helicopter may be operated at less than the minimums pres cribed in paragraph (b) or (c) of this section, provided each person oper ating the helicopter complies with any routes or altit udes specifically prescribed f or helicopters by the
FAA.

Commercial UAS operations will be conducted at or below the max imum altitude authorized by COA. Given the si ze, weight and lack of fuel; com bined with operation limitations listed below, the operation will be conducted with a greater level of safety than exists with current m anned aviation operations.

 14 C.F.R. 91.121 – Altimeter Settings Each person operating an aircraft shall maintain the cruising a ltitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating... SUAS are equipped with Global Positioning System (GPS), which p rovide altitude and geolocation data to the operator without utilizing an altimeter. D ue to this fact, an exemption is required. GPS are precise within a few feet and combined with f ail-safes and a visual observer the operation will meet an equivalent level of safety.

 14 C.F.R. 91.151(a) – Fuel Requireme nts for Flight in VFR Condi tions

o No person may begin a flight in an airplane under VFR condition s unless (considering wind and forecast weather conditions) there is eno ugh fuel to fly to the first point of intended landing and, assuming normal cruisi ng speed— (1) During the day, to fly after t hat for at least 30 minutes;

This regulation is written based on the capabilities of a tradi tional aircraft, which have flight times of several hours or greater; therefore, with the m ajority of sUAS which have flight times of only an hour or less, this regulation would eff ectively deny the ability of the air vehicle to operate.

The PIC will achieve an equivalent level of safety by complying with all manufacturer guidelines and the manufacturers’ low battery failsafe system.January 25, 2016 Page 8 of 13

 14 C.F.R. 91.215(b) – ATC Transponder and Altitude Reporting Eq uipment and
Use.

o All airspace. Unless otherwise au thorized or directed by ATC, n o person may operate an aircraft in the airspace described in paragraphs (b) (1) through (b)(5) of this section, unless that aircr aft is equipped with an operable coded radar beacon transponder having either Mode 3/A 4096 code capability, replyi ng to Mode 3/A interrogations with the code specified by ATC, or a Mode S capa bility, replying to Mode 3/A interrogations with t he code specified by ATC and i ntermode and Mode S interrogations in accordance with the applicable provisi ons specified in TSO C-112, and that aircraft is equipped with automatic pressur e altitude reporting equipment having a Mode C capability that automatical ly replies to Mode C interrogations by transm itting pressure altitude informa tion in 100-foot increments. This requirement applies—

(1) All aircraft. In Class A, C lass B, and Class C airspace are as;

(2) All aircraft. In all airspace within 30 nautical miles of a n airport listed in appendix D, section 1 of this part f rom the surface upward to 1 0,000 feet MSL;

(3) Notwithstanding paragraph (b)(2) of this section, any aircr aft which was not originally certificated with an e ngine-driven electrical system or which has not subsequently been certified with such a system installed, ballo on or glider may conduct operations in the airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part provided such operations are conducted—

(i) Outside any Class A, Class B, or Class C airspace area; and

(ii) Below the altitude of the ceiling of a Class B or Class C airspace area designated for an airport or 10,000 f eet MSL, whichever is lowe r; and

(4) All aircraft in all airspace above the ceiling and within t he lateral boundaries of a Class B or Class C airspace area designated for an airport upward to 10,000 feet MSL; and

(5) All aircraft except any aircraft which was not originally c ertificated with an engine-driven electrical system or which has not subsequently b een certified with such a system instal led, balloon, or glider—

(i) In all airspace of the 48 contiguous states and the Distric t of Columbia at and above 10,000 feet MSL, excluding the airspace at and below 2,50 0 feet above the surface; andJanuary 25, 2016 Page 9 of 13

(ii) In the airspace from the surface to 10,000 feet MSL within a 10-nautical-mile radius of any airport listed in appendix D, section 2 of this p art, excluding the airspace below 1,200 feet outside of the lateral boundaries of the surface area of the airspace designate d for that airport.

The sUAS to be used in the proposed operation does not come equ ipped with a transponder. No transponder exists for the sUAS, which can be i nstalled. The petitioner requests relief from the exempti on to the extent required to op erate in areas in which a transponder is required according the applicable regulations inthis part.

The PIC will achieve an equivalent level of safety by complying with all provisions of the COA under which operations are to be conducted. By issuing appropriate NOTAMS and prior ATO coordination, an equivalent level of safety can b e achieved as other manned aircraft, which receive au thorization to fly in airspace where a transponder is required but not operable. In or der to give proper notice to th e ATO, the PIC will comply with the provisions of 91.215(d)(3 ). The sUAS flown under this exemption will comply with all altitude limits and airport standoff distances require d by COA, which mitigate hazards to aircraft controlled by the ATO in congested airspace

.

 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) – Maintenance Inspections

o 91.405(a) States : Each owner or operator of an aircraft—(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of th is section, have discrepancies repaired as pres cribed in part 43 of this chapter

o 91.407(a)(1) States : (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless—(1) It has been approved for return to service by a person authorized unde r § 43.7 of this chapter

o 91.409(a)(2) States: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had—(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. No inspection performe d under paragraph (b) of this section may be substituted for any inspection requi red by this paragraph unless it is performed by a person authorized to perf orm annual inspections and is entered as an ‘‘annual’’ inspection in the r equired maintenance records.

o 91.417(a) & (b) States: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this sect ion: (paragraphs 1 (i – iii), 2 (i – vi)); (b) The owner or operator shall retain the following records for the periods prescribed: (paragraphs 1 – 3)January 25, 2016 Page 10 of 13

The PIC will conduct Pre/Post flight inspections and maintenanc e in accordance with the manufacturer’s guidance as state d in the operations manual. If maintenance is required, the PIC will conduct a dedicated test flight will be conducted to ensure safety before resuming commercial operations. All inspection, maintenance and alterations will be documented and maintained in a record. These actions will meet the intent of the regulations from which exemption is being requested and lead to an equivalent level of safety.

II. Commercial Operator/Operation

Any UA flown under this exemption will be controlled by a certi ficated PIC. The PIC will hold, at a minimum, a recreational or sport pilot certificate.

For each flight, Jorge Delgado:

 Will contact the controlling air traffic organization to issue a NOTAM.

 Will conduct a comprehensive worksite inspection and analysis, identifying limits of customer property or authorized access areas.

 Will conduct preflight planning in accordance with Section 91.1 03 Preflight Action.

 Will operate in those areas only with the consent of the landow ner or designated representative.

 Will identify potential obstructions or other hazards to safe o peration.

 Will clear the area of personnel or bystanders that are non-ess ential to the operation, maintaining at a minimum, 500 feet away from non-participating persons.

 Will conduct a preflight safety briefing to Visual Observer (VO ) and participating

persons.

 Will at all times yield to manned air traffic.

 Will operate within VLOS of both PIC and VO during daylight hours only.

 Will maintain voice communications with VO and participating pe rsons.

 Will operate under visual flight r ules, in visual meteorologica l conditions, for the airspace in which the flight is conducted.

 Will not exceed the maximum altitude as defined in the COA unde r which flight authorized, as determined by the installed GPS.

 Will keep operating documents, manuals, authorizations and exemptions in a binder colocated with the GCS.

 Will immediately terminate flight, in the safest manner possibl e, when safety to persons or property become compromised.

 Will terminate flight, in the safest manner possible, when unab le to comply with these limitations or any other limitati ons granted as part of this ex emption.

In order to remain at an altitude at or below the attitude pres cribed by the applicable COA, relief is needed from Section 91.119 (c). By following these operating standards, the commercial operation will meet an equivalent l evel of safety to the regula tion in which relief is sought.January 25, 2016 Page 11 of 13

III. Unmanned Aircraft System

Jorge Delgado seeks exemption to operate sUAS as outlined above . Other UAS types may be requested in future amendments. The UA will be flown via a comb ination of RC control and tablet GCS. All UA types are GPS equipped with a navigation and control system and auto-pilot that allows it to execute very accurate pre-programmed flights. Lithium-polymer batteries power the sUAS.

The UA also has several fail-safes for loss of RC signal, loss of GPS, and low battery as outlined in the respective Operation Manuals. The UA display visual and emit an audible low battery alerts at which time the UA will automatically engage the landi ng sequence. Based upon those safeguards, I request exemption from Section 91.151(b) Fuel req uirements for flight in VFR conditions.

Given the size, weight, speed, and controlled operating area as sociated with the UA to be utilized, an exemption from 14 CFR part 21, Subpart H (Airworth iness Certificates) and § 91.203 (a) and (b) is requested. Exemption is sought from § 45. 23 Marking of the aircraft. The UA will display the registration number in the largest practica ble lettering. Jorge Delgadoseeks to be exempt from § 91.405(a), 91.407(a)(1), 91.409(a)(2) and 9 1.417(a) and (b) Maintenance inspections will be conducted according to operations manual and prudent ju dgment as previously outlined to determine the integrity and safety of th e UA and associated equipment. Further, relief is required from 91.7(a), which prohibits the o peration of an aircraft without an airworthiness certificate and 91.9( b) (2) requiring an approved flight manual in the aircraft. The UA will not be operating with an airworthiness certificate ther efore, this would be inappropriate. The UAS are too small to carry the operating documents so an eq uivalent amount of safety can be achieved through keeping the operating documents and manuals at the GCS.

IV. UAS Pilot in Command (PIC)

Under part § 61, recreational, sport and private pilots are lim ited to non-commercial operations, however Jorge Delgado can ensure UA operations will achieve an equivalent level of safety as current regulation because UA do not carry any pilots or passen gers. A commercial pilot certificate will not ensure RC piloting ability, as the psychom otor skills are different. The inherent risks of operating a UAS are far less than in the comm ercial activities outlined in 14 CFR part 61, et seq., thus exemption is requested from § 61.101 Recreational Pilot Privileges and Limitations. PICs will maintain recent flight experience on the UAS. Trainin g and experience flights will be conducte d separate from commercial o perations.

V. Public Interest

Given the above stated evidence, procedures, and precautions op erating UAS commercially for the purposes of aerial photography, aerial videography, data co llection and other work related toJanuary 25, 2016 Page 12 of 13

aerial photography will ultimately be in the public interest. T hese operations, when executed with prudence, will exceed the current level of safety as the r egulations from which exemption is sought. UA operations will allow greater access to commercial a erial services that were not previously economically feasible for many firms. This will prov ide a much needed economic uplift to the community and he nce the public. UA operations are associated with less risk of collateral damage to persons and property while limiting disrup tive noise pollution associated with low altitude aviation operations.

VI. Summary

Pursuant to Section 333 of PL 112-95 commonly known as the “FAA Modernization and Reform Act of 2012”, Jorge Delgado, hereby applies for authorization t o conduct commercial unmanned aerial systems (UAS) operations f or the purposes of aerial phot ography, aerial videography, data collection and other work relat ed to aerial photography listing s Rules for which exemption is sought:

 14 C.F.R. Part 21 Subpart H

 14 C.F.R. § 45.23(b)

 14 C.F.R. § 61.101, 61.113 and 61.133(a)(1)(ii)

 14 C.F.R. § 91.7(a)

 14 C.F.R. 91.9(b)

 14 C.F.R. § 91.103

 14 C.F.R. § 91.109(a)

 14 C.F.R. § 91.119

 14 C.F.R. § 91.121

 14 C.F.R. § 91.151(a)

 14 C.F.R. § 91.215(b)

 14 C.F.R. § 91.405(a)

 14 C.F.R. § 91.407(a)(1)

 14 C.F.R. § 91.409(a)(2)

 14 C.F.R. § 91.417(a) & (b)

VII. Attachments :

1. Specific Appendixes and UAV manuals. (These documents have been provided electronically by email since it is confidential and proprietar y and is not to be publicly disclosed.)January 25, 2016 Page 13 of 13

Thank you for your prompt attentio n and consideration. Traver se Legal and its clients are committed to safe UAS operation and ambassadors. Please do no t hesitate to contact me directly with any questions or concerns at 866-936-7447.

Very truly yours,

Traverse Legal, PLC

Enrico Schaefer Attorney at Law www.dronelaw.pro enrico@traverselegal.com

ES/cam Enclosures